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June 11, 2019

New Victorian Economic Entitlement Provisions – Developers Beware!

On 6 June 2019, the State Taxations Acts Amendment Bill 2019 (the Bill) passed both houses of Victorian parliament and at the time of writing is awaiting royal assent. The Bill makes significant and far-reaching changes to the Duties Act 2000 (Vic). This article discusses, in particular, the “economic entitlement” provisions contained in the Bill….

January 22, 2019

DAA announcement – Egidija Popovic and Lee Just

It is our great pleasure to recognise the the hard work and focus that Egidija and Lee have brought to DAA.  This announcement from Daniel Allison, Senior Principal and founder of Daniel Allison & Associates… Egidija Popovic – Client Director Egidija joined DAA’s predecessor firm 30 years ago, and since that time has been a…

December 11, 2018

Only partial foreign tax offset for US capital gains

A single judge of the Federal Court has agreed with the Commissioner that a taxpayer was only entitled to a 50% foreign income tax offset (FITO) for US tax paid on the sale of investments: Burton v FCT [2018] FCA 1857. An Australian resident taxpayer sold investment assets located in the US. The whole of…

November 1, 2018

DAA announcement – Jane Clark and David Everist

With our sustained and continued growth there can be challenges for the practice but more importantly, opportunities for our team. It therefore gives us great pleasure to announce significant promotions for Jane Clark and David Everist.   The promotion of these founding team members is a testament to their hard work, dedication and contribution to the success of DAA. Jane Clark – Principal Jane has proven herself to be…

October 30, 2018

Sweeping shareholder loan changes proposed

Treasury has issued a Consultation Paper proposing major changes to the Division 7A regime. The Paper is the Government’s response to an earlier Board of Taxation review, however the proposed changes go much further than the Board’s recommendations. The proposals are subject to further consultation, therefore may be altered before being legislated. The proposed start…

March 23, 2018

DAA announcement – Fikreta Skopljak

It is with great pleasure that we announce the promotion of Fikreta Skopljak to the role of Principal at Daniel Allison & Associates. Fikreta has been an integral part of our team since the firm’s inception in 2009 and, as a superannuation specialist, oversees our super advisory and compliance practice area.  With her conscientious and…

March 8, 2018

ATO Guidance on the Meaning of “Carrying on a Business”

The ATO has issued a draft taxation ruling to explain the factors it will consider when deciding whether a company (incorporated under the Corporations Act 2001) is “carrying on a business”. This is one of the tests companies and small businesses must pass to be eligible for the lower corporate tax rate. As this is…

March 6, 2018

New Passive Income Test for Lower Corporate Tax Rate

The Federal Government has recently introduced a Bill into Parliament to ensure that companies with more than 80% passive income, will not qualify for the reduced 27.5% company tax rate otherwise available to companies that carry on a business and have an aggregated turnover below the prescribed relevant threshold ($25 million for 2017–2018). Under the…

August 14, 2017

ATO Allows Refinance of UPEs Placed on 7-year Interest Only “Sub-trust” Loans

The ATO has released guidelines (PCG 2017/13) which will allow trusts to refinance unpaid entitlements (“UPEs”) of corporate beneficiaries to the income of a trust that were converted to a 7 year interest only loan, where the principal component was due to be repaid either by 30 June 2017 or 30 June 2018. Under the…

August 8, 2017

Transfer pricing: interest rate on borrowing not arm’s length

In a major transfer pricing judgment (“the Chevron Case”), the Full Federal Court has unanimously dismissed Chevron Australia’s appeal, finding that its loan arrangement with its related US company, Chevron Texaco Funding Corporation, was not at arm’s length and the Commissioner was justified in denying Chevron Australia’s interest deduction claims. At the crux of the…

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